France: New guidance on Pillar Two rules; notice on common Pillar Two reporting errors

New guidance aligned with OECD GloBE model rules and commentary.

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OCTOBER 17, 2025

The tax authorities on October 8, 2025, issued new guidance aligned with the OECD global anti-base erosion (GloBE) model rules and commentary, providing clarifications and examples on different aspects of the Pillar Two rules in France, including with respect to the scope of application and territoriality.

The tax authorities also announced that additional guidance is being drafted, focusing on:

  • Application of safe harbor rules
  • Calculation of effective tax rate (ETR)
  • Calculation of top-up tax liability
  • Application of charging mechanisms
  • Transitory rules
  • Clarifications on filing and payment

Read an October 2025 report prepared by KPMG’s EU Tax Centre


The tax authorities also released a notice on common Pillar Two reporting errors. The notice also includes additional filing instructions.

Read an October 2025 report prepared by KPMG’s EU Tax Centre

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